A business risk management approach to PV equipment installation that incorporates environmental, health, and safety (EHS) considerations from the planning process through start-up can help reduce costs, minimize liability, and minimize timeframes.
by Brent Wilson MPH, senior EHS consultant, EORM, and Varun Gopalakrishna, Principal, Avani Design Consulting
June 17, 2009 – As the photovoltaic (PV) industry expands and ramps up R&D and manufacturing operations, there are opportunities to reduce cost, minimize liability, and minimize equipment installation timeframes through a business risk management approach to equipment installations, one that incorporates environmental, health, and safety (EHS) considerations from the planning process through to the start up of the equipment.
Business risk management
Business risk management that includes environmental health and safety (EHS) risk management considerations results in a smooth equipment installation process that anticipates issues and resolves those issues before the equipment is installed and placed into production. When EHS issues are identified post-installation, the cost impact can be significant, involving production down time, rework of equipment/facilities and significant employee man-hours to restore the situation. Including the EHS function as a key stakeholder early in the installation process can reduce the risk of incurring these direct and indirect costs once the equipment installation is complete.
Once the equipment is selected the planning can begin — with the potential EHS risks posed by the equipment and process being defined and EHS selection criteria communicated to the internal stakeholders and equipment suppliers to ensure the equipment is designed to meet the requirements of applicable codes (e.g. NFPA, NEC, Fire and Building Code), regulations (OSHA, EPA), guidelines (e.g. SEMIR S2, SEMIR S8), and other expectations of the purchaser. The equipment design will be evaluated against these selection criteria to ensure it complies with the communicated expectations. This evaluation could include inspections of the equipment at the equipment supplier site to ensure that the equipment has been built to design and no further changes are necessary. Identifying required improvements prior to shipment of the equipment will avoid the need for costly field modifications and delayed equipment start-up. Acceptance of the equipment should also be contingent on the delivery of all key documentation such as equipment manuals, lock-out tag-out procedures, PM procedures, and facility installation specifications. The planning phase is vital since unaddressed EHS issues at this phase will impact each subsequent phase.
Equipment installation design phase
Once the facility installation specifications (e.g., footprint, utility requirements, P&ID) are received, the physical and regulatory aspects of facility “readiness” can be addressed. Many authorities having jurisdiction (AHJ), such as the local fire department, require a permit package to be submitted prior to equipment installation. This package typically includes professional engineer stamped design drawings, updated hazardous materials inventory statements (HMIS), building occupancy classification (BOC) tables, and if applicable, details of the facility’s life safety system. The EHS function is typically the owner of much of this regulatory documentation and can assist in their preparation for submittal. EHS participation in this phase will ensure regulatory compliance of the facility modifications, the equipment layout, material compatibilities, and potential environmental impacts such as discharges to the air or water. Based on this review the EHS programmatic, operational, and permit impacts of the equipment installation can be evaluated and steps taken to address these through new/amended environmental permits, exposure assessments, review of chemistries, and process hazard analyses (PHA), etc.
The key benefit of EHS involvement during the equipment installation design phase is to identify EHS issues early and allow them to be mitigated prior to installation.
Equipment installation phase
Construction will typically begin once the AHJ has issued the permit for equipment installation with their comments and changes to the design. A facility may choose to take the risk and begin equipment installation prior to the permit being issued. However, if the AHJ has significant changes to the design, rework can be costly. When proper planning and design with EHS input has been done, the rework during the installation is minimal.
Equipment start-up phase
The final opportunity to mitigate business risk is during the equipment start-up phase. The elements which were identified early in the design and planning phases are now verified through an installation sign-off process. The process should employ a structured approach while establishing accountability for completion of outstanding items. A proven equipment sign-off model uses a three-stage process that requires an inspection and sign-off at each stage to manage the occupational hazards from the utilities that are released for use in that stage.
- Stage one: Ensures that the tool is suitable for energization and non-process qualification and releases power and non-hazardous, non-process utilities (CDA, N2, PCW, etc.). This step allows for the tool to be safely energized, robotics calibrated, software loaded and prepares for the subsequent installation and qualification steps. In addition, building systems required for occupancy, egress, safe equipment-working clearances and required support equipment are verified.
- Stage two: Validates that all internal and external safety systems and facilities are implemented for the equipment to safely receive all process utilities including hazardous chemistries. This stage will also require final issuance of all agency permits. Once Stage Two is complete, the equipment is released to be qualified for process.
- Stage three: Allows for production acceptance and includes the review of operating and maintenance specifications, necessary pre-production industrial hygiene baseline exposure assessments for chemical and physical agents, and any outstanding punch-list items from the previous stages are completed.
Identifying and addressing EHS considerations as early as possible in the installation of production or R&D equipment takes advantage of the opportunities to avoid significant post-installation costs, delays, and liabilities resulting in an overall lower EHS risk and business risk.
Brent Wilson MPH is senior EHS consultant at Environmental and Occupational Risk Management (EORM). E-mail: firstname.lastname@example.org.
Varun Gopalakrishna is principal at Avani Design Consulting. E-mail: Varung_00@yahoo.com.